AI Act guidelines: definition of an AI system (Article 3(1))

Published by the Commission on 6 February 2025 and formally adopted on 29 July 2025 as C(2025) 5053 final, these guidelines help determine whether a software system is an 'AI system' under Article 3(1) of the AI Act. They break the definition into seven elements: machine-based; designed to operate with some autonomy; may show adaptiveness after deployment; explicit or implicit objectives; infers from input how to generate outputs; outputs such as predictions, content, recommendations or decisions; and can influence physical or virtual environments. The guidelines are non-binding and will be updated with practical experience.